On September 3, 2013 the AUA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the Medicare Physician Fee Schedule for calendar year 2014. In the comment letter, a number of concerns were expressed about the proposed policy changes for the coming year. Above all concerns is the AUA’s staunch opposition to CMS’ proposal to cap payment for non-facility services at the hospital outpatient department (OPD) or ambulatory surgical center (ASC) facility rate when the non-facility payment amount exceeds the facility payment amount for the same service.

In the comment letter, the AUA urged CMS to withdraw the proposal, because payments for facility and non-facility services are determined under vastly different reimbursement methodologies. Several other flaws were identified with the credibility of the proposal for capitated payment. For example,CMS proposes to compare the 2014 non-facility practice expense relative value units to the 2013 OPD/ASC payment rates. In some cases, this will result in significant disparities between the OPD/ASC cap and the actual rate that would be paid in these settings in 2014. In the proposal, CMS also offers several exclusions. For one of these exclusions, CMS would exempt any service that is performed 5 percent or less in the OPD setting; however, the agency provides no data or discussion about whether an exemption would apply to services rarely performed in the ASC.

AUA comments on the proposed rule also raised new and ongoing concerns with several proposals to carry out mandatory quality program initiatives. In 2014, CMS proposes to expand the reporting requirements for the Physician Quality Reporting System (PQRS) from three to nine measures. While this requirement might meet the goals of the PQRS program, the AUA believes it does not consider the resource burden the policy would place on some specialists, like urologists, that have fewer than nine measures available for reporting. The AUA believes many of the proposed changes to the PQRS, the Value-Based Payment Modifier and the Physician Compare website were not fully conceived. The AUA offers several recommendations in its comments to ease and enhance member participation in CMS’ quality programs. Read the AUA full comment letter to CMS.